JP2020061002A - Foreign exchange transaction control device, foreign exchange transaction control method and program - Google Patents

Abstract

To provide a foreign exchange transaction control device that can be sharedly used by a plurality of financial institutions, and that executes an AML check on an overseas remittance data and updates a list for the AML check on the basis of an AML check result by a financial institution actually performing an operation of overseas remittance.SOLUTION: The foreign exchange transaction control device executes a first AML check on destination remittance request data on the basis of a first list associated with individual financial institutions and when the first AML check shows a first determination result, transmits an AML check processing completion notification to a first financial institution system associated with the destination remittance request data, and when a determination result of a second AML check by a second financial institution system shows a second determination result, updates the first list on the basis of a determination basis and reason transmitted by the second financial institution system.SELECTED DRAWING: Figure 8

Description

  The present invention relates to a foreign exchange transaction control device, a foreign exchange transaction control method, and a program. More specifically, the present invention performs an AML (Anti-Money Laundering) check on the overseas remittance data requested by the customer, and updates the AML check list based on the check result. The present invention relates to a control device, a foreign exchange transaction control method, and a program.

  In order to prevent money laundering, Japan has enacted the Act on Prevention of Transfer of Criminal Proceeds in light of international trends such as the request of the Financial Action Task Force on Money Laundering (FATF). We are calling for financial institutions to take appropriate measures to prevent money laundering.

  Banks verify their identities using official documents when opening an account, and perform AML checks to prevent money laundering during overseas remittances. The AML check is performed, for example, by checking whether or not it corresponds to an individual or a group listed in the list provided by the Ministry of Finance of Japan, a foreign government agency, etc. Is different for each bank, and so is the accuracy of the list.

  Money laundering is the disguise of money obtained through fraudulent transactions as if it was legal by moving an account or investing in foreign real estate, especially when sending money. Is known to do. Transfer of funds between accounts can occur either by domestic remittance or overseas remittance, but it is known as a conventional technique that the mechanism of domestic remittance and overseas remittance is different.

  Domestic remittances are carried out by the Zengin System and the BOJ-NET, financial institutions nationwide are connected online, and the transfer from the customer is credited to the transfer account on the same day (the next business day depending on the time zone), and Payments between financial institutions are being made on the same day. For this reason, the customer can enjoy almost the same service regarding domestic remittance at any financial institution in the country.

  On the other hand, overseas remittance is carried out through a system that covers most financial institutions in the world called SWIFT (Society for Worldwide Interbank Financial Telecommunication: Swift) (Patent Document 1). For overseas remittances, there is no universal system equivalent to the BOJ-NET, which is responsible for the settlement of funds, so the settlement of funds between banks is done via major international banks. Correspondent agreements are indispensable for conducting such foreign exchange transactions directly with overseas banks, and direct transactions cannot be made between banks that do not have correspondent agreements. Correspondence contracts are contracts relating to the exchange business that banks individually conclude. Therefore, depending on whether you request an international major bank (with a correspondent contract) for overseas remittance directly, or if you request another bank and that bank relays the request to the major international bank, the overseas remittance will be performed. It takes a few days to reach the other party, and it usually takes at least 1 to 2 days, and in some cases several days, to complete the remittance.

JP, 2016-122265, A

  The timing of performing the AML check includes the time of opening an account, the time of accepting a transaction, and the time of executing a transaction. For the AML check at the time of opening an account, some measures have been taken at each financial institution, such as thorough identification of the individual. However, the accuracy of the AML check at the time of accepting a transaction and at the time of executing a transaction varies depending on the financial institution. In foreign exchange operations such as remittance to Japan (remittance from Japan to overseas), it is essential to perform an AML check when sending a message received from a customer overseas. It was done. Some financial institutions have data received from customers in the Internet banking (IB) system, but the AML check mechanism is not linked with the IB system. For this reason, the AML check is performed manually, which imposes a heavy burden on the bank staff, and many mistakes are made by manually inputting English sentences and ambiguous searches. If the AML check is inadequate, the financial institution itself may be subject to fines, etc., so that for the financial institution, the skill of the AML check may lead to business risk.

  Further, the contents of the list used for the AML check may be different depending on the management scale of the financial institution and the range of business handled. The list provided by the Ministry of Finance is available to each financial institution, but the list published by a foreign government institution depends on whether the financial institution can bear the cost and the financial institution that does not. There is an institution.

  In addition, transactions that do not send overseas remittance telegrams are outsourced to other banks, but they are not sufficiently shared as a result of the AML check between the consignment bank and the consignment bank.

  The present invention has been made in order to solve such a problem, can be shared by a plurality of financial institutions, and can perform AML check on the overseas remittance data requested by the customer. It is an object of the present invention to provide a foreign exchange transaction control device, a foreign exchange transaction control method, and a program for updating a list for AML check based on the result of AML check by a financial institution performing an overseas remittance operation. It is another object of the present invention to provide a foreign exchange transaction control device, a foreign exchange transaction control method, and a program that can sufficiently support the sharing of results of AML checks even when an office work is outsourced.

  The foreign exchange transaction control apparatus, which is an aspect of the present invention, executes a first anti-money laundering (AML) check on the received remittance request data based on the first list associated with each financial institution. If the first AML check shows a first determination result, an AML check processing completion notification is transmitted to the first financial institution system associated with the destination remittance request data, and the processing completion notification When the determination result of the second AML check by the second financial institution system, which is executed later, indicates the second determination result, based on the determination basis reason transmitted by the second financial institution system, It is configured to update the list of ones.

  According to another aspect of the present invention, there is provided a foreign exchange transaction control method executed by a foreign exchange transaction control device, which is based on a first list associated with an individual financial institution. Performing a money laundering (AML) check, and if the first AML check indicates a first determination result, the AML check of the first financial institution system associated with the remittance request data is performed. When the determination result of the second AML check by the second financial institution system, which is executed after the notification of the processing completion and is executed after the notification of the processing completion, indicates the second determination result, the second financial institution Updating the first list based on the justification reason sent by the system.

  According to the present invention, it is possible to provide a function of performing an AML check in a foreign exchange transaction control device that can be shared by a plurality of financial institutions. The foreign exchange transaction control device according to the present invention can perform the AML check on the overseas remittance data requested by the customer, and for the AML check based on the AML check result by the financial institution actually performing the overseas remittance operation. You can update the list. The foreign exchange transaction control device of the present invention can support the sharing of the result of the AML check between the administrative consignment bank and the consignment bank.

A detailed understanding of the embodiments disclosed herein can be obtained from the following description, which is illustrated in connection with the accompanying drawings.
1 is a configuration diagram of an entire system including a foreign exchange transaction control device according to the present invention. It is a system configuration diagram of a foreign exchange transaction control device according to the present invention. It is a figure explaining an example of a data structure of a customer master. It is a figure explaining an example of the data structure of a common list. It is a figure explaining an example of the data structure of an individual list. It is a figure explaining an example of the data structure of remittance to a destination. It is a figure explaining an example of the data structure of the past judgment history. It is a figure explaining the AML check process before a destination remittance performed by the foreign exchange transaction control device which concerns on this invention. It is a figure explaining an example of a screening result inquiry screen. FIG. 9 is a flow diagram illustrating an embodiment in which a first bank controlling a first bank system outsources a remittance operation to a second bank controlling a second bank system. It is a flowchart explaining the embodiment which the 2nd bank which controls a 2nd bank system transmits a remittance remittance telegram by itself through a SWIFT network, without entrusting office work to another bank.

  Hereinafter, embodiments of the present invention will be described in detail. There are two types of foreign exchange remittances: destination remittance (Japan to overseas remittance) and destination remittance (overseas to Japan remittance). Although the present description describes an embodiment for remittances, the idea of the invention is also applicable to remittances. Further, the technical idea of the present invention can be applied to virtual currency transactions.

(overall structure)
FIG. 1 is a configuration diagram of an entire system including a foreign exchange transaction control device 100 according to the present invention. The foreign exchange transaction control device 100 is connected to one or a plurality of customer terminals 110 so as to be able to communicate with each other via a known network such as the Internet or a private line. The foreign exchange transaction control device 100 is communicatively connected to one or more first bank systems 120 and one or more second bank systems 130 via a known network. The first bank system 120 and the second bank system 130 are communicatively connected to each other via a known network. The second bank system 130 can mutually communicate with overseas financial institutions via the SWIFT network 140. Although not shown in FIG. 1, in another embodiment of the present invention, the first bank system 120 may be able to communicate with a foreign financial institution via the SWIFT network 140.

  The foreign exchange transaction control device 100 is a device that provides various functions related to foreign exchange business, and is used as an ASP server that provides an ASP service that can be shared by a plurality of financial institutions. The foreign exchange transaction control device 100 can function as a shared-use internet banking (IB) system, and can also function as a system for performing an AML check. The foreign exchange transaction control device 100 may be configured such that the function as the shared IB system and the function as the system for performing the AML check are executed by one device, or they are executed by different devices. May be configured as. The foreign exchange transaction control device 100 mutually communicates with one or more financial institution systems (for example, the first bank system 120 and the second bank system 130) that use the ASP service, and transmits and receives various information. You can In this specification, the ASP service and the SaaS (Software as a Service) type service can be used interchangeably.

  The foreign exchange transaction control device 100 can provide the customer terminal 110 with a web page of a screen for foreign exchange transaction as one function of the IB system. The foreign exchange transaction control device 100 can receive a request for foreign exchange transaction (for example, a demand remittance request) from the customer terminal 110, and can perform the AML check described in the present specification according to the information included in the request. The foreign exchange transaction control device 100 can transmit the screening result of the AML check to the bank systems 120 and 130. The person in charge of the bank uses the bank terminal (not shown) communicatively connected to the foreign exchange transaction control device 100 and the bank system (the first bank system 120 or the second bank system 130) to screen the AML check. You can refer to the result. The foreign exchange transaction control device 100 can transmit the request remittance request to the bank system (the first bank system 120 or the second bank system 130) indicated in the request remittance request.

  The customer terminal 110 is a terminal used by a customer (for example, a corporate customer) who desires a foreign exchange transaction (for example, overseas remittance) as exemplified in this specification, and is a personal computer (PC), a smartphone, a tablet terminal, or the like. The computer can be provided with the communication function of. The customer terminal 110 can communicate with the bank system (first bank system 120 or second bank system 130) of the transaction bank via the foreign exchange transaction control device 100. The customer terminal 110 can have an application program such as a web browser for browsing the web page of the foreign exchange transaction screen received from the foreign exchange transaction control device 100. The customer terminal 110 can transmit a demand remittance request to the foreign exchange transaction control device 100 via the web page of the foreign exchange transaction screen.

  The first bank system 120 is a bank system controlled by a first bank with which a customer who uses the customer terminal 110 makes a transaction. In the present specification, since the first bank cannot send the remittance remittance telegram by itself through the SWIFT network 140, it is necessary to outsource the work to the second bank that controls the second bank system. Is. The first bank system 120 maintains an individual list 208 for AML checks, updates the individual list 208 in response to receiving a screening result of the AML check from the second bank system 130, and controls foreign exchange transactions. The personalized list 208 associated with the first bank stored in the device 100 can be updated (synchronization process).

  The second bank system 130 is a bank system that is controlled by a second bank that receives an overseas remittance administrative task from the first bank that controls the first bank system 120. The second bank system 130 has an accounting system and a foreign exchange-related system, performs an AML check based on the received request for remittance, and sends the remittance to the overseas counterpart bank via the SWIFT network 140. You can send a message.

  Although only one customer terminal 110, one first bank system 120, and one second bank system 130 are shown in FIG. 1 for convenience of explanation, a plurality of these may exist. A bank terminal (not shown) used by a person in charge of the bank can access the foreign exchange transaction control device 100 and the bank system (the first bank system 120 or the second bank system 130). Although the foreign exchange transaction control device 100 is described as one device in this specification, various processes executed by the foreign exchange transaction control device 100 may be configured to be distributed and executed by a plurality of devices. Further, in the above-mentioned embodiment, the first bank outsources the overseas remittance to the second bank, but the first bank has its own accounting system and foreign exchange-related system. , It may be possible to perform an AML check based on the received request for remittance, and send a remittance remittance telegram to the overseas counterpart bank via the SWIFT network 140. It may be possible to selectively use the above and the subcontracting.

(System configuration)
FIG. 2 is a system configuration diagram of the foreign exchange transaction control device 100 according to the present invention. As shown in FIG. 2, the foreign exchange transaction control device 100 includes a control unit 201, a main storage unit 202, an auxiliary storage unit 203, an interface (IF) unit, which are connected to each other by a bus 220 or the like, like a general computer. It is provided with 204 and an output unit 205. Further, the foreign exchange transaction control device 100 includes a customer master 206, a common list 207, an individual list 208, a remittance 209, and a past determination history 210 in the form of a file / database or the like.

  The control unit 201 is also called a central processing unit (CPU), controls each component in the foreign exchange transaction control device 100, calculates data, and stores various programs stored in the auxiliary storage unit 203 as main storage. It can be read out to the unit 202 and executed. The main storage unit 202 is also called a main memory, and can store various received data, computer-executable instructions, data after arithmetic processing by the instructions, and the like. The auxiliary storage unit 203 is a storage device represented by a hard disk (HDD) or the like, and is used when storing data and programs for a long period of time.

  2 illustrates an embodiment in which the control unit 201, the main storage unit 202, and the auxiliary storage unit 203 are provided in the same computer, but as another embodiment, the foreign exchange transaction control device 100 includes the control unit 201. It is also possible to realize parallel distributed processing by a plurality of computers by using a plurality of main storage units 202 and auxiliary storage units 203. Further, as another embodiment, it is possible to adopt an embodiment in which a plurality of servers for the foreign exchange transaction control device 100 are installed and the plurality of servers share one auxiliary storage unit 203.

  The IF unit 204 serves as an interface when transmitting and receiving data to and from other systems and devices, and also provides an interface that receives various commands and input data (various masters, tables, etc.) from the system operator. You can The output unit 205 can provide a display screen for displaying the processed data, a printing unit for printing the data, and the like.

  The customer master 206 is a master file that stores information about customers who have transactions with one or more financial institutions that use the ASP service. A customer whose data is stored in the customer master 206 can access the foreign exchange transaction control device 100 through the customer terminal 110 and perform foreign exchange transactions such as remittance to destination. FIG. 3 is a diagram illustrating an example of the data structure of the customer master 206. The customer master 206 can include a customer ID 301, basic information 302, and a transaction financial institution code 303, but is not limited to these data items and can include other data items.

  The customer ID 301 is an identifier for identifying a customer who has a transaction with a financial institution that uses the ASP service. As described above, the foreign exchange transaction control device 100 can be used as an ASP server that provides an ASP service that can be shared by a plurality of financial institutions. Therefore, when a customer is transacting with a plurality of financial institutions, the foreign exchange transaction control device 100 is the same. There are as many customer IDs 301 as are associated with the customers of the above-mentioned customers. For example, if the customer company A trades with three financial institutions, there may be three customer IDs 301 associated with company A. The customer ID 301 also functions as a user ID when the customer accesses the page of the foreign exchange transaction screen provided by the foreign exchange transaction control device 100.

  The basic information 302 includes a customer's name, address, contact information, account information established by a transaction financial institution, etc., but is not limited to the information shown in this specification. The transaction financial institution code 303 is an identifier that identifies the financial institution with which the customer is transacting. The foreign exchange transaction control device 100 can identify the bank system 120, 130 to be communicated with based on the transaction financial institution code 303 associated with the customer ID 301 used for login.

  Returning to FIG. 2, the common list 207 stores the data of the common list used by all the financial institutions using the ASP service for the AML check. The common list 207 is a list provided by the Japanese Ministry of Finance (MOF), the United Nations (UN), the United States government agency (for example, Office of Foreign Assets Control (OFAC)). Depending on the country of remittance, there are countries that are under stricter regulations than Japan, so the common list 207 is configured to include a list applicable to those countries. The common list 207 is updated based on the updated information each time the information provider updates the information.

  FIG. 4 is a diagram illustrating an example of the data structure of the common list 207. The common list 207 can include a common list_name 401, a common list_BIC code 402, and an information provider 403, but the common list 207 is not limited to these data items and can include other data items. is there.

  The common list_name 401 is one or more names of the sanction target person / organization, etc. provided by the information provider. The common list_name 401 includes information such as a payee name and a bank name associated with the payee. However, the sanctioned person / organization may use a different name or may use multiple financial institutions. Therefore, there can be a plurality of pieces of information such as the payee name and the bank name. The common list_BIC code 402 is a financial institution identification code used in the SWIFT network 140 to identify the bank of the remittance destination. The common list_BIC code 402 may indicate a plurality of pieces of information when the common list_name 401 stores a plurality of bank names. The BIC code may also be called a SWIFT code or a SWIFT address. The information provider 403 indicates a government agency, an international agency, or a private agency that has provided the information stored in the common list 207.

  Returning to FIG. 2 again, the individual list 208 stores the data of the individual list used by each financial institution using the ASP service for the AML check. Some financial institutions have their own AML checklists built through operations such as remittances. The personalized list 208 can be updated by individual financial institutions depending on the result of the AML check.

  FIG. 5 is a diagram illustrating an example of the data structure of the individual list 208. The individual list 208 can include a financial institution code 501, an individual list_name 502, and an individual list_BIC code 503, but is not limited to these data items and can also include other data items. is there.

  The financial institution code 501 is an identifier that identifies a financial institution that has its own AML check list. The financial institution code 501 may be associated with the transaction financial institution code 303. The individual list_name 502 includes information such as the name of the payee and the name of the remittance destination bank indicated by the unique AML checklist constructed through the operation of the remittance to the destination. The individual list_name 502 may indicate a plurality of pieces of information such as the name of the payee and the name of the bank to which the money is remitted, because the person to be sanctioned / group or the like may use another name or may use some financial institutions. . The individual list_BIC code 503 is a financial institution identification code used to identify the bank of the remittance destination in the SWIFT network. The individual list_BIC code 503 may indicate a plurality of pieces of information when a plurality of remittance destination bank names are stored in the individual list_name 502.

  Returning to FIG. 2 again, the ordered remittance 209 is a file that stores the transaction contents of the ordered remittance generated in response to the requested remittance request received from the customer terminal 110 and the data generated in the subsequent process. FIG. 6 is a diagram illustrating an example of the data structure of the remittance 209. Remittance remittance 209 includes transaction acceptance ID 601, remittance source account 602, remittance sender name 603, remittance destination BIC code 604, recipient account 605, recipient name 606, remittance currency 607, remittance amount 608, application date 609, remittance designation date 610, The status 611, the screening result 612, the trail 613, the consignment financial institution code 614, and the customer ID 301 can be included, but the data items are not limited to these data items and can include other data items.

  The transaction acceptance ID 601 is an identifier that identifies a series of processes associated with the ordered remittance request received from the customer terminal 110, and is assigned by the foreign exchange transaction control device 100 when the ordered remittance request is received. The customer ID 301 indicates the customer ID of the customer associated with the received remittance request. The remittance source account 602 indicates the account of the customer who has made the requested remittance request. The remitter name 603 indicates the name of the customer who has transmitted the ordered remittance request, and may be an account name associated with the remitter account 602. The remittance destination BIC code 604 is an identifier for identifying the remittance destination financial institution indicated by the destination remittance request. The payee account 605 indicates the payee's bank account indicated by the destination remittance request. The payee name 606 indicates the name of the payee indicated by the requested remittance request (for example, the account name associated with the payee account 605). The remittance currency 607 indicates the type of currency to be remitted (eg, Japanese yen, US dollar, etc.). The remittance amount 608 indicates the remittance amount indicated by the requested remittance request. The application date 609 indicates the date on which the remittance request is sent. The designated remittance date 610 is a date designated by the customer to actually transmit the remittance remittance telegram via the SWIFT network 140, and may be a date several days ahead of the application date 609, for example.

  The status 611 indicates the processing status of the requested remittance request, for example, information such as AML checked, transmission completed to the transaction bank, and the like. The screening result 612 indicates the result of the AML check, and, for example, “does not match (OK)” indicating that the information does not match the information of the sanctioner / organization, “needs confirmation (gray)” indicating suspicious, and matches. It indicates information such as “match (NG)” indicating that. The trail 613 shows the reason why the financial institution has determined that there is no problem in the purpose of remittance remittance in response to the demand remittance request determined to be “confirmation required (gray)” as a result of the AML check. The consignment financial institution code 614 is an identifier for identifying the second bank to which the first bank which received the request for remittance remittance from the foreign exchange transaction control device 100 has outsourced the administrative work.

  Returning to FIG. 2 again, the past determination history 210 is a file that stores information on a demand remittance request under the same conditions as a transaction that has already been determined by the same customer. As a result of the AML check performed by the foreign exchange transaction control device 100, it was once determined to be “confirmation required (gray)”, but the information on the requested remittance request updated by the financial institution to “not consistent (OK)” is: It is recorded in the past determination history 210. The past determination history 210 can be used to eliminate the need for a second AML check if a request for remittance under the same conditions is made by the same customer within a predetermined period. is there. Note that in another embodiment of the present invention, the foreign exchange transaction control device 100 executes the AML check and indicates “confirmation required (gray)” even when a request for remittance under the same conditions occurs at the same customer. It may be configured to refer to the past determination history 210 when it is determined.

  FIG. 7 is a diagram illustrating an example of the data structure of the past determination history 210. The past determination history 210 may include a customer ID 301, a sender account 602, a sender name 603, a recipient BIC code 604, a recipient account 605, a recipient name 606, a screening result 612, a trail 613, and an update date 701. However, the data items are not limited to these data items and may include other data items. The customer ID 301, the sender account 602, the sender name 603, the recipient BIC code 604, the recipient account 605, the recipient name 606, the screening result 612, and the trail 613 are the data items described with reference to FIGS. 3 and 6. Same content. The update date 701 is the latest date when a request for remittance under the same conditions is issued by the same customer. If the date indicated by the update date 701 is within a predetermined number of days from the date of receiving a new remittance request, the foreign exchange transaction control device 100 omits the AML check by referring to the past determination history 210. can do. As described above, in another embodiment of the present invention, the foreign exchange transaction control device 100 may execute the AML check regardless of the date of the update date 701 and the date of newly receiving the remittance request. .

(Processing flow: AML check)
Next, referring to FIG. 8, the AML check process before the remittance to a destination executed by the foreign exchange transaction control device 100 according to the present invention will be described. FIG. 8 is a diagram for explaining the AML check process before the remittance to a destination executed by the foreign exchange transaction control device 100 according to the present invention. This processing flow describes the AML check for the remittance to the destination (remittance from Japan to overseas), but the same technical idea can be applied to the remittance to the destination (remittance from overseas to Japan). . In another embodiment of the present invention, the foreign exchange transaction control device 100 can perform the AML check based on the sender information and the recipient information included in the destination remittance message.

  In step S801, the customer terminal 110 accesses the foreign exchange transaction control device 100, inputs the customer ID 301, password, etc., and logs in. The foreign exchange transaction control device 100 acquires the transaction financial institution code 303 associated with the customer ID 301 from the customer master 206, and displays the web page of the foreign exchange transaction screen of the financial institution on the customer terminal 110. When the customer presses the remittance request button after inputting the information for the remittance to the customer through the customer terminal 110, the foreign exchange transaction control device 100 checks whether or not there is inconsistency in the input data, and if there is no problem. , Transaction acceptance ID 601 is generated, and a demand remittance request including input data is generated. The foreign exchange transaction control device 100 receives a demand remittance request from the customer terminal 110 and stores data in the destination remittance 209.

  In S802, the foreign exchange transaction control device 100 reads the data of the requested remittance request stored in the directed remittance 209. The foreign exchange transaction control device 100 performs the AML check of the sender information based on the sender name 603 of the read data, and the recipient information of the receiver information based on the recipient BIC code 604, the recipient account 605, and the recipient name 606. Perform AML check. The sender account 602 is not subject to the AML check because the sender account 602 has been verified at the time of opening the account and the sender account 602 cannot be changed at the time of transfer. However, the sender name 603 can be changed when inputting the transfer data. Therefore, it is subject to the AML check.

  More specifically, the foreign exchange transaction control device 100 identifies the financial institution code 501 corresponding to the transacting financial institution code 303, reads information of the individual list 208 of the financial institution based on the identified financial institution code 501, A first collation process is performed to determine whether the sender information and the recipient information match the information in the read individual list 208. Further, the foreign exchange transaction control device 100 performs a second collation process of whether or not the sender information and the recipient information match the information stored in the common list 207. The processing order of the first matching process and the second matching process is not particularly limited, and any matching process may be performed first. The foreign exchange transaction control device 100 determines whether or not there is data corresponding to the list as a result of the first matching process and the second matching process. The determination result (screening result 612) may be “not matching (OK)”, “confirmation required (gray)”, and “matching (NG)”. If there is corresponding data in the list, the process proceeds to S803, and if there is no corresponding data, the process proceeds to S805.

  In another embodiment of the present invention, the foreign exchange transaction control device 100 can also perform a fuzzy search during the AML check in order to reduce the risk of omission of check. The ambiguous search is a search method in which if the data matching rate in the first matching process and the second matching process is within a predetermined range (for example, XX% or more match), it is determined as a match. Is. In a further embodiment of the present invention, the foreign exchange transaction control device 100 may refer to the data of the past determination history 210 and perform the AML check of the same remittance request for the same customer. In such a case, the foreign exchange transaction control device 100 performs the first collation process and the second collation process for the data that matches the data included in the data of the past determination history 210 (the data that is determined to be “not matched (OK)”). The collation process of can be omitted.

  In S803, the foreign exchange transaction control device 100 transmits the screening result 612 to the bank system 120 or the bank system 130 to which the remittance request is to be transmitted. The transmitted screening result 612 is information indicating whether or not the sender information and / or the payee information matches the list in one or both of the first matching process and the second matching process. including. In response to receiving the notification of the screening result 612, the person in charge of the financial institution confirms the content of the data of the remittance request associated with the screening result 612 via the terminal connected to the bank system 120 or the bank system 130. can do.

  Here, an example of the screening result inquiry screen 900 will be described with reference to FIG. 9. The screening result inquiry screen 900 shows the content and processing status of the requested remittance request to each financial institution. The screening result inquiry screen 900 displays the data stored in the remittance 209 and also an inquiry button for displaying the details of the selected data.

  The person in charge of the financial institution refers to the screening result inquiry screen 900 by using the terminal connected to the bank system 120 or the bank system 130, and presses the inquiry button for the data whose screening result is "confirmation required". . When the inquiry button is pressed, the foreign exchange transaction control device 100 can read the selected data from the remittance 209 and display the screening result on a pop-up screen as shown in FIG. In the example of FIG. 9, the inquiry button is pressed for the data with the transaction acceptance ID “123456”, and the sender name “does not match (OK)”, the recipient name “confirmation required (gray)”, and the recipient account are displayed on the popup screen. An example in which a screening result such as "match (NG)" is displayed is shown. Further, in another embodiment of the present invention, when the inquiry button is pressed, the foreign exchange transaction control device 100 can read the selected data from the remittance remittance 209 and display the screening result on the next screen.

  In S804, the person in charge of the financial institution uses the bank terminal connected to the bank system 120 or the bank system 130 to "match" the screening result 612 for the remittance request determined to be "confirmation required (gray)". When the screening result 612 is updated to “not match (OK)” or “match (NG)” and the screening result 612 is updated to “not match (OK)”, the reason is registered in the trail 613. The foreign exchange transaction control device 100 stores the screening result 612 and the trail 613. The stored screening result 612 can record the initial determination result and the updated determination result.

  The foreign exchange transaction control device 100 transmits to the customer terminal 110 a notification that the request cannot be accepted, to the customer who has made the request for remittance of goods determined to be “match (NG)”. When the customer terminal 110 determines that the item is “matched (NG)”, the customer terminal 110 withdraws the request for remittance, or corrects the information at the relevant portion of the request for remittance, and sends the request again to the foreign exchange transaction control device 100. You can In such a case, the foreign exchange transaction control device 100 performs the AML check as described in S802 on the received remittance request.

  In step S <b> 805, the foreign exchange transaction control device 100 updates the status 611 of the data of the remittance request for delivery, in which the screening result 612 indicates “does not match (OK)”, to “transmitted (or processed)”, and The processing completion notification of the AML check is transmitted to the bank system 120 or the bank system 130 specified by the data. The processing completion notification can include data items such as, but not limited to, the transaction acceptance ID 601 and the designated remittance date 610.

(Processing flow: Office consignment)
In FIG. 10, the first bank, which controls the first bank system 120, outsources the operation of remittance from Japan (remittance from Japan to overseas) to the second bank, which controls the second bank system 130. It is a flow figure explaining an embodiment.

  In S1001, the first bank system 120 reads out the data of the corresponding remittance request from the remittance 209 based on the transaction acceptance ID 601 included in the processing completion notification received from the foreign exchange transaction control device 100. The first banking system 120 can update the consignment financial institution code 614 by selecting the second bank as the business consignment destination based on the information stored in the read data of the requested remittance request. The second bank, which is the business consignment destination, may be predetermined by the first bank, or the data content of the requested remittance request (for example, the remittance destination BIC code 604, the recipient account 605, the remittance currency 607, etc.). May be dynamically selected based on The first bank system 120 can transmit the data of the demand remittance request read from the foreign exchange transaction control device 100 to the second bank system 130.

  When data is transmitted to the second bank system 130 after the number of days has passed since the AML check by the foreign exchange transaction control device 100, in the embodiment of the present invention, the first bank system 120 causes the foreign exchange transaction control device 100 to operate. Alternatively, the latest common list 207 and the individual list 208 may be used to perform the AML check, and the checked remittance remittance request data may be received again and then transmitted to the second bank system 130. The first bank system 120 notifies the second bank system 130 of the screening result 612 and the trail 613 included in the data of the remittance request, so that the AML check performed by the first bank which is the consignment bank. The result of can be shared with the second bank.

  In step S1002, the second bank system 130 performs an AML check on the data of the requested remittance request received from the first bank system 120, against the AML check list held by the bank. More specifically, the second bank system 130 determines whether the sender information and the recipient information included in the data of the requested remittance request match the information stored in the AML check list held by the bank. Perform matching processing. The second bank system 130 can also send an inquiry message to the first bank system 120 regarding the screening result 612 and the trail 613 received in S1001. The AML check list held by the second bank system 130 may be different from the common list 207 and the individual list 208 associated with the first bank.

  In step S1003, the second bank system 130 determines whether or not the remitter information and the recipient information included in the data of the requested remittance request correspond to the list as a result of the AML check. If the result of the AML check indicates “confirmation required (gray)” or “match (NG)”, the process proceeds to S1004, and if it indicates “not match (OK)”, the process proceeds to S1007.

  In S1004, second bank system 130 notifies first bank system 120 of the result of the AML check performed by second bank system 130. When the result of the AML check indicates “confirmation required (gray)” or “match (NG)”, the second bank system 130 determines whether the determination is made from the AML check list held by the second bank system 130. It is possible to read the reason that is the basis and send the reason for the determination basis to the first bank system 120. The reason for this determination basis can indicate the sender information, the recipient information, and the information provider. In response to the reception of the reason for this determination, the person in charge of the first bank accesses the foreign exchange transaction control device 100 from the first bank system 120 through the terminal and performs the AML check performed by the second bank system 130. As a result, the screening result 612 for the requested remittance request determined to be “confirmation required (gray)” is updated to “not match (OK)” or “match (NG)” and the screening result 612 is “not match ( When updating to “OK)”, the reason can be registered in the trail 613. The foreign exchange transaction control device 100 stores the screening result 612 and the trail 613. The stored screening result 612 can record the initial determination result and the updated determination result.

  In S1005, the first bank system 120 can access the foreign exchange transaction control device 100 and add the information of the reason for judgment received from the second bank system 130 to the common list 207, and / or It can also be added to the individual list 208 as data associated with one bank. The individual list 208 of the first bank system 120 and the individual list 208 of the foreign exchange transaction control device 100 can be processed synchronously.

  In S1006, first bank system 120 reads out the data of the demand remittance request including updated screening result 612 and trail 613 from foreign exchange transaction control device 100, and sends the read out information to second bank system 130. . The second bank system 130 stores the received information in the second bank system 130.

  In S1007, the second bank system 130 sends the data of the demand remittance request, which is determined to be “not coincident (OK)” in S1003, or the remittance demand received from the first bank system 120 in S1006. A remittance remittance telegram is generated based on the requested data and transmitted to the SWIFT network 140. The sent remittance telegraphic message is received by the payee's banking system.

  In another embodiment of the present invention, the first bank, which is a consignment bank, responds to a demand remittance request determined to be “confirmation required (gray)” as a result of the AML check performed by the second bank. If it cannot be determined to be either “no match (OK)” or “match (NG)”, the decision can be delegated to the second bank. In such a case, the first bank system 120 asks the second bank system 130 to determine whether the second bank corresponds to “not matching (OK)” or “matching (NG)”. Can be asked to receive the result of the judgment. Based on the received judgment result, the first bank system 120 can access the foreign exchange transaction control device 100 and update the data of the requested remittance request of the remittance remittance 209.

(Processing flow: No outsourcing)
FIG. 11 is a flowchart illustrating an embodiment in which the second bank that controls the second bank system 130 itself transmits the remittance telegraphic message via the SWIFT network 140, without outsourcing the work to another bank. is there.

  In step S1101, the second bank system 130 reads the data of the requested remittance request from the requested remittance 209 based on the transaction acceptance ID 601 included in the processing completion notification received from the foreign exchange transaction control device 100. When the application date 609 and the designated remittance date 610 included in the read data of the requested remittance request indicate different dates, the foreign exchange transaction control device 100 can be requested to re-execute the AML check for the requested remittance request. Since the common list 207 and the individual list 208 may have different contents as of the application date 609 and as of the designated remittance date 610, the second bank system 130 again executes the AML before the transmission to the SWIFT network 140. You can check.

  When the above-mentioned AML check is requested and the screening result 612 received from the foreign exchange transaction control device 100 indicates “confirmation required (gray)”, in S1102, the person in charge of the second bank makes a second check through the bank terminal. The foreign exchange transaction control device 100 is accessed from the bank system 130, and the data of the demand remittance request determined to be “confirmation required (gray)” is updated to “does not match (OK)” or “matches (NG)”. The reason for the update can be stored in the trail 613. After the update processing is performed, the foreign exchange transaction control device 100 can send the updated data of the demand remittance request to the second bank system 130.

  In addition, when the result of the AML check is that it is “matched (NG)”, the second bank system 130 can notify the customer terminal 110 of that fact through the foreign exchange transaction control device 100.

  In S1103, the second bank system 130 sends the data of the requested remittance request in which the application date 609 and the designated remittance date 610 included in the data of the requested remittance request read in S1101 are the same date, or the AML check described above. Is completed, and based on the data of the demand remittance request received from the foreign exchange transaction control device 100 in S1102, the destination remittance telegram is generated and transmitted to the SWIFT network 140. The sent remittance telegraphic message is received by the payee's banking system.

  In the above-described embodiments of the present invention, actual currencies (eg, US dollars, Japanese yen, etc.) have been described as an example, but the AML check scheme according to the present invention can also be applied when sending virtual currencies. Even when sending virtual currency, the information of the sender and the recipient is recorded in the transaction record. Therefore, the foreign exchange transaction control device 100 determines whether or not the common list 207 and the individual list 208 are satisfied based on the information of the sender and the recipient before being recorded in the transaction record, and whether to continue the transaction thereafter. You can judge whether.

  Although the principle of the present invention has been described above with reference to exemplary embodiments, those skilled in the art can realize various embodiments that are modified in the configuration and details without departing from the gist of the present invention. Will understand. That is, the present invention can be embodied as a system, a device, a method, a program, a storage medium, or the like.

100 foreign exchange transaction control device 110 customer terminal 120 first bank system 130 second bank system 140 SWIFT network 201 control unit 202 main storage unit 203 auxiliary storage unit 204 interface (IF) unit 205 output unit 206 customer master 207 common list 208 Individual list 209 Remittance 210 Past judgment history 220 Bus 900 Screening result inquiry screen

Claims (11)

It is a foreign exchange transaction control device,
Perform a first anti-money laundering (AML) check on the received remittance request data based on a first list associated with an individual financial institution,
When the first AML check indicates the first determination result, the AML check processing completion notification is transmitted to the first financial institution system associated with the destination remittance request data,
When the determination result of the second AML check by the second financial institution system executed after the notification of the processing completion shows the second determination result, the reason for the determination is transmitted by the second financial institution system. A forex trading controller configured to update the first list based on the   The first AML check includes performing a first collation process of whether or not the sender information and the recipient information included in the ordered remittance request data match the information in the first list. The foreign exchange transaction control device described in 1. When the first AML check shows a second determination result, the second determination result is transmitted to the first financial institution system associated with the destination remittance request data,
The foreign exchange transaction control device according to claim 1, further configured to receive update data for the second determination result from the first financial institution system.   The foreign exchange transaction control device according to claim 3, wherein the update data for the second determination result includes an updated determination result and an update reason.   The method further comprising transmitting an AML check processing completion notification to the first financial institution system associated with the remittance remittance request data updated based on the update data for the second determination result. Item 3. A foreign exchange transaction control device. A second list that can be shared by multiple financial institutions,
The foreign exchange transaction control device according to claim 1, further configured to update the second list based on the determination basis reason transmitted by the second financial institution system.   The first AML check further includes performing a second collation process of whether or not the sender information and the recipient information included in the ordered remittance request data match the information in the second list. Item 7. A foreign exchange transaction control device. Further equipped with past judgment history data,
The foreign exchange transaction control according to claim 1, wherein the first AML check includes determining whether or not the sender information and the recipient information included in the ordered remittance request data are included in the past determination history data. apparatus.   The second financial institution system is a system controlled by a second financial institution that has been outsourced for an overseas remittance operation from the first financial institution that controls the first financial institution system. The foreign exchange transaction control device described in 1. A foreign exchange transaction control method executed by the foreign exchange transaction control device,
Performing a first anti-money laundering (AML) check on received remittance request data based on a first list associated with an individual financial institution;
When the first AML check shows a first determination result, transmitting a processing completion notification of the AML check to the first financial institution system associated with the remittance request data.
When the determination result of the second AML check by the second financial institution system executed after the notification of the processing completion shows the second determination result, the reason for the determination is transmitted by the second financial institution system. Updating the first list based on the foreign exchange transaction control method.   A program that, when executed by a processor, causes a forex trading controller to perform the method of claim 10.

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